IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel that the status conference in the above-captioned matter now set for July 28, 2011, may be continued to August 19, 2011 at 10:00 A.M.

This continuance is at the request of both counsel for to allow time for proper preparation and to permit plea negotiations between the parties with the intention of conserving time and resources for both parties and the court. Since the last court date, the government has extended an offer to Ms. Ford. Defense has discussed a counter-proposal with the government. The government is currently drafting the language to that counterproposal.

Additionally, the court moved Ms. Ford's status conference from a Friday to a Thursday, which conflicts with her work schedule. The parties anticipate if the court grants this continuance there will be a resolution on the requested date.

The parties agree that the delay resulting from the continuance shall be excluded in the interests of justice, including but not limited to, the need for the period of time set forth herein for effective defense preparation and continuing plea negotiations purposes pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).

ORDER

Time is excluded pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv). Good Cause has been stated.

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